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The frightening public health impacts of the overuse of antibiotics to raise animals for food are becoming clear. The Centers for Disease Control and Prevention (CDC)

estimate that over 2 million Americans contract an antibiotic-resistant infection each year, leading to at least 23,000 deaths.1

But fewer people realize that the aquaculture industry also

has an antibiotics problem. Just like raising livestock and

poultry, many large-scale fish farming operations rely on the

misuse and overuse of antibiotics to compensate for crowded,

stressful conditions.

Many fish and other seafood are given low doses of antibiotics

in feed over long periods of time to try to prevent the spread

of illness.2 These practices lead to the development and spread

of antibiotic-resistant bacteria. Imagine taking a low dose of

antibiotics every day to prevent getting sick, rather than going

to the doctor to get a prescription or antibiotics when you

actually are sick.3

Aquaculture production has grown substantially over the last

several decades. According to the United Nations Food and

Agriculture Organization (FAO), total global aquaculture pro-

duction has reached nearly 67 billion tons.4 Aquaculture has

risen from just over 13 percent of total global fish production

to 42 percent since 1990.5

The use of antibiotics in aquaculture varies widely around the

world.6 Since most of the seafood that we eat in the United

States is imported, practices used around the world have the

potential to affect anyone who consumes seafood.7 The risks

from this poorly regulated industry include residues of antibi-

otics and other drugs that remain in the products that we eat,

as well as antibiotic-resistant bacteria created by the overuse

of antibiotics.8

Factory Fish FarmsLike factory farms on land, large-scale factory fish farms in

the oceans are generally big, dirty and dangerous. Marine

fish are grown in cages or net pens that allow uneaten fish

feed, fish waste and any antibiotics or chemicals used in the

operation to flow through the cages directly into the ocean.9

Pesticides and the other drugs or chemicals used in these

operations can also be damaging to the surrounding aquatic

ecosystem.10 Caged fish can escape and compete for resources

or interbreed with wild fish and weaken important genetic

traits, and farmed fish can also spread disease to wild fish.11

Factory fish farms also tend to grow top-of-the-food-chain

carnivorous fish that require large amounts of protein in their

diet.12 That protein generally comes from small wild fish — like

herring and sardines — that are extracted in large quantities

Issue Brief • April 2016

HOW FACTORY FISH FARMSMISUSE ANTIBIOTICS

2

from the ocean and processed into feed.13 In some cases it

can take over six pounds of wild fish to produce one pound of

farmed fish.14 Taking wild fish out of the ocean to feed farmed

fish can undermine the marine food chain by reducing a food

source for other wild fish.15 Soy is also being extensively added

to feed, yielding excess waste and pollution.16 Fish raised in

freshwater ponds in Asia are often fed “homemade” feed,

consisting of kitchen scraps and chicken parts, which may

increase the risk of Salmonella.17

Uninspected Imports Currently, more than 9 out of 10 fish that Americans eat are

imported, and about half of all imported fish and seafood are

raised on fish farms.18 In the developing world, fish farmers

often use veterinary drugs and fungicides that are unapproved

in the United States in order to combat disease in overcrowd-

ed fish pens. The U.S. Food and Drug Administration (FDA) is

increasingly concerned that U.S. fish imports contain residues

of these drugs and chemicals, some of which can cause cancer

and allergic reactions and contribute to the development of

antibiotic-resistant bacteria.19

U.S. government inspectors do not examine enough imports

to find all of the unapproved and dangerous chemicals in

imported fish. About 2 percent of imported fish and seafood

shipments is physically inspected or tested in laboratories.20

The low level of inspection leaves consumers vulnerable to

foodborne illnesses and to exposure to common chemicals

and drugs used in overseas aquaculture operations that are

illegal in the United States. In 2012, the CDC found that

imported fish were the most common source of foodborne ill-

ness outbreaks from imported foods between 2005 and 2010.21

The European Union (EU) found four times more veterinary

drug violations on imported seafood annually than the United

States did because the EU inspected a vastly higher percent-

age of imports, between 20 and 50 percent.22

How Antibiotic Misuse Leadsto Antibiotic ResistanceAll species evolve in response to their environment, includ-

ing bacteria. Antibiotics kill bacteria, but if a few bacteria

withstand the treatment, these bacteria will not only survive,

but reproduce and pass on the genetic traits that allow them

to resist exposure to antibiotics.23 Even more troubling, most

antibiotic-resistance genes occur on mobile pieces of DNA

that can be shared among bacteria, a process known as hori-

zontal gene transfer.24

The gene sharing can occur among the bacteria in animal

digestive tracts and then continue as bacteria from the animal

spread via waste into the environment.25 The resistance gene,

in a way, takes on a life of its own, no longer tied to a spe-

cific species of bacteria but persisting in the larger microbial

environment. The collective effect is known as “reservoirs of

resistance,” in which resistance genes are widespread in the

environment and can be acquired by other bacteria.26 The

routine use of antibiotics over long periods of time creates the

ideal conditions for creating antibiotic-resistant bacteria.

Antibiotic Use in AquacultureRaising many animals in close quarters poses challenges to

maintaining good health, and fish are no exception. Bacte-

rial diseases — and antibiotic use to manage those diseases

— are very common due to stress and hygiene issues in these

artificially crowded conditions. Better sanitation and vaccines

make it possible to use far fewer antibiotics in certain parts of

the aquaculture industry, but those practices are not widely

used, especially in developing countries.27 Aquaculture uses

large amounts of a wide variety of antibiotics, including those

important to human medicine.28

So what happens when antibiotics are used in aquaculture?

Treating the fish with medicated feed creates conditions in

which antibiotic-resistant bacteria can spread within the fish.

This treatment also creates the possibility of drug residues in

seafood (see specific cases below).29

But the fish do not eat all of the medicated feed, and most of

the antibiotics pass through the digestive system and are re-

leased into the environment in animal waste. Antibiotics that

remain in the water place selective pressure on bacteria living

in it, leading to the development and spread of antibiotic re-

sistance near aquaculture facilities. Prophylactic use of antibi-

otics in shrimp and salmon aquaculture has led to higher rates

of resistance in bacteria in the surrounding waters. Addition-

ally, antibiotics in the water affect other marine life nearby.30

Evidence suggests that these antibiotic-resistant bacteria can,

in turn, pass on their antibiotic resistance genes to other bac-

teria, including human and animal pathogens, through hori-

3

zontal gene transfer.31 An increasing number of studies have

documented elevated levels of bacterial antibiotic resistance

in and around aquaculture sites. For example, before 1990 in

the United Kingdom, the disease-causing bacteria Aeromo-

nas salmonicida were sensitive to amoxicillin. But after the

antibiotic was introduced to fish farms, amoxicillin-resistant

strains began to appear.32 Evidence of antibiotic-resistant

bacteria also has been reported in the Mediterranean Sea,

where a study found a high percentage of resistant strains,

indicating a widespread antibiotic resistance in the bacterial

populations surrounding fish farms.33

Case Study: Salmon Farmsin Norway and ChileThe world’s top two salmon-producing countries, Norway

and Chile, use vastly different amounts of antibiotics. Incred-

ibly, Chilean salmon producers use 840 times more antibiotics

per ton of fish than Norwegian salmon producers. Norwegian

salmon producers use only very small amounts of antibiotics,

less than a gram of antibiotics per ton of salmon produced,

compared to over half a kilogram of antibiotics per ton of

salmon in Chile.34 What can explain this glaring disparity?

In Norway, producers transitioned to vaccines and hygiene

management practices, reserving antibiotics only for emer-

gencies.35 The Norwegian Veterinary Institute developed a

vaccine against the disease furunculosis, which came into

common use during the 1990s through collaboration between

the government and industry.36

Industrial salmon farming in Chile has grown rapidly into

a robust export industry, making Chile the top supplier

of salmon to the United States.37 Heavy antibiotic use

has fueled that growth at every step of the way.38 Chilean

salmon producers have struggled with diseases for which

there are no vaccines.39 Chile permits the use of several

classes of antibiotics in salmon production that are banned

for such uses in Norway, the United States and Canada,40

including substantial use of quinolones, a class of antibiotics

unapproved for such uses in the United States. The FDA

has cited three companies operating in Chile for using

unapproved antibiotics and other drugs.41 Researchers have

further analyzed antibiotic sales data, determining that Chile

effectively neither regulates nor tracks antibiotic use in the

salmon industry.42

The heavy use of antibiotics in Chilean salmon facilities has

lead to an increase of antibiotic-resistant bacteria there.43

Moving young salmon from freshwater hatcheries to marine

facilities further spreads antibiotic-resistant bacteria around

the environment.44 Antibiotic-resistance genes that emerged

in aquatic bacteria have been found in human and animal

pathogens nearby.45 For example, some antibiotic-resistant

urinary tract infections in Chilean people have been linked

to antibiotic misuse in salmon aquaculture.46 Research sug-

gests that aquaculture workers may be at risk as well.47

Case Study: Aquaculture in AsiaAsia dominates global aquaculture production, producing

nearly 90 percent of the world’s total.

Most Asian aquaculture occurs in freshwater or brackish

ponds, which release water into nearby water bodies, allow-

ing chemical use to degrade the local aquatic ecosystem. Not

just antibiotics, but many other veterinary medicines, are

commonly used.48 Antibiotics have been used in low doses,

such that some of the treatments are no longer effective.49

Imported catfish from Vietnam has undercut a substantial

U.S. catfish farming industry over the last several years. To

level the playing field, the 2008 U.S. Farm Bill required that

imported catfish undergo the same level of inspection as

domestic catfish. This change was highly controversial, with

much debate about whether such measures are necessary.50

But a risk assessment of chemical use in Asian aquaculture

found catfish farming in Vietnam to be among the worst

possible “hot spots” due to its intensive production practices

and heavy chemical use.51 Vietnamese catfish production

uses relatively higher levels of antibiotics than other forms

of aquaculture in Asia.52 A limited study of antibiotic use in

Asian aquaculture found 17 different antibiotics being used

in surveyed Vietnamese catfish farms, including several

antibiotics used in human medicine.53 One class of medi-

cally important antibiotics, fluoroquinolones, was recently

banned in aquaculture in Vietnam after several drug-residue

violations were found by countries such as the United States

and Canada, where fluoroquinolones may not be used in

aquaculture.54 There is ongoing research on vaccines to use

instead of antibiotics in Vietnamese catfish production, with

few effective results thus far.55

The high use of antibiotics in intensive catfish production

in Vietnam has lead to a reservoir of antibiotic-resistance

genes that can spread between species in the Mekong River

4

Delta.56 A recent study found multi-drug resistance in nearly

all the samples tested of Pseudomonas, a common aquatic

bacteria on Vietnamese catfish farms. Stunningly, one sample

of Aeromonas, another fish pathogen, was resistant to all 13

antibiotics tested.57 These types of bacteria are “ubiquitous”

in the aquatic environment and include both fish and human

pathogens.58

Currently, the FDA has an Import Alert in place that orders

all shipments from 13 Vietnamese seafood exporters to be

seized for the illegal use of enrofloxacin, an antibiotic in the

fluoroquinolones class, for violations dating back to 2009.59

The FDA banned the use of fluoroquinolones in fish and other

food animals “based on evidence” that widespread use “would

promote the evolution of drug-resistant pathogens” and that

consumers could be exposed to this risk on their food because

the drug-resistant bacteria would remain on the fish after they

were processed.60

ShrimpAs with catfish, antibiotic misuse in shrimp production in

Asia has fostered multi-drug-resistant bacteria.61 Vietnamese

shrimp farms have used as many as 30 different antibiotics,

including those important in human medicine.62 In Vietnam,

researchers found the presence of bacteria resistant to antibi-

otics used in shrimp farming in coastal areas to be relatively

common. Antibiotic residues in water and mud near the

shrimp facilities are a problem as well.63

Tests of shrimp imports offer a window into the impacts of

antibiotic use in production. A study comparing imported

shrimp with wild shrimp from South Carolina found antibi-

otic resistance to be more common in some imports. Patterns

of resistance in samples from Ecuador, India and Thailand

reflected antibiotics that are heavily used in those countries’

shrimp industries.64

A 2015 Consumer Reports survey found that 80 percent of the

bacteria commonly found on shrimp from Vietnam were resis-

tant to one or more classes of antibiotics, suggesting that the

shrimp were exposed to these antibiotics in their environment.65

The survey also found residues of several classes of antibiotics

on shrimp from Vietnam, and 72 percent of the shrimp with

antibiotic residues in the study were from Vietnam.66

The Trans-Pacific Partnership (TPP) trade deal is a 12-nation

trade pact being considered by Congress in 2016. The deal cov-

ers 40 percent of the global economy and significant agricul-

ture-, food- and fish-producing countries in the Pacific Rim.

Agribusiness and food companies demanded that the TPP

include provisions to allow corporations to attack food safety

laws as illegal trade barriers.

The TPP could force the United States to accept inadequate

food safety standards as “equivalent” to ours.67 TPP coun-

tries that permit antibiotics use in aquaculture could use the

TPP to attack U.S. food safety rules that block the import of

seafood raised with banned antibiotics. The TPP even has pro-

visions that could allow exporters to try and force U.S. border

inspectors to allow seafood contaminated with antibiotics to

be imported into the United States.

The FDA inspects only around 2 percent of imported seafood.

But even this limited amount of sampling reveals problems.

The FDA rejected one-fifth of seafood shipments from the TPP

nations of Vietnam and Malaysia (23 percent and 20 percent,

respectively) — about twice the overall refusal rate of 10

percent. Illegal antibiotics are a common reason that the FDA

rejects imports from fish farming powerhouses like China,

Vietnam and Malaysia — and is often the most common

reason (see Figure 1).68 Prioritizing trade with those countries

rather than improving standards and increasing inspection of

imports puts us all at risk.

What Can Consumers Do?Choosing sustainably raised seafood takes work on the part of

consumers. Food & Water Watch recommends that consumers

read labels to see if seafood is from the United States and if

it is wild-caught or farm-raised. For more information about

choosing good seafood options, check out our seafood guide.

With so much imported seafood, however, we cannot shop our

way out of this problem. Tell your elected officials to require

more inspection of imported fish and to oppose new trade

deals that increase unsafe imports.

FIGURE 1: Percent of FDA Import Refusals for Illegal Antibiotics (2010–2014)

SOURCE: Food & Water Watch analysis of FDA FOIA data and Import Refusal Report 2010 to 2014. Available at http://www.accessdata.fda.gov/

scripts/ImportRefusals/index.cfm. Accessed December 2015.

100

80

60

40

20

0All Vietnam China Malaysia

5

Endnotes1 U.S. Centers for Disease Control and Prevention (CDC). “Antibiotic Resis-

tance in the United States, 2013.” 2013 at 6.

2 Cabello, Felipe et al. “Antimicrobial use in aquaculture re-examined: its

relevance to antimicrobial resistance and to animal and human health.”

Environmental Microbiology. Vol. 15, Iss. 7. 2013 at 1918.

3 See Food & Water Watch. “Antibiotic Resistance 101: How Antibiotic Use

on Factory Farms Can Make You Sick.” 2015.

4 United Nations Food and Agriculture Organization. “The State of World

Fisheries and Agriculture.” 2014 at 3 to 4.

5 Ibid. at 19.

6 Cabello et al. (2013) at 1919.

7 U.S. Department of Commerce National Marine Fisheries Service. “Fisher-

ies of the United States 2012.” September 2013 at 81; U.S. GovOversight

Resources.” (GAO-12-933.) September 2012 at 5.

8 Cabello et al. (2013) at 1917.

9 Upton, Harold F. and Eugene H. Buck. “CRS Report for Congress: Open

Ocean Aquaculture.” Congressional Research Service. August 9, 2010 at 1 to

2; Cabello, Felipe. “Heavy use of prophylactic antibiotics in aquaculture: a

growing problem for human and animal health and for the environment.”

Environmental Microbiology. Vol. 8, Iss. 7. 2006 at 1138.

10 Marine Aquaculture Task Force. “Sustainable Marine Aquaculture: Fulfilling

the Promise; Managing the Risks.” January 2007 at 74 to 76.

11 Jenson, O. et al. “Escapes of fishes from Norwegian sea-cage aquaculture:

causes, consequences and prevention.” Aquaculture Environment Interac-

tions. Vol. 1. 2010 at 71; Marine Aquaculture Task Force (2007) at 49.

12 Goldburg, Rebecca and Rosamond Naylor. “Future seascapes, fishing, and

fish farming.” Frontiers in Ecology and the Environment. Vol. 3, Iss. 1. 2005 at

21 and 23.

13 Tacon, Albert and Marc Metian. “Fishing for feed or fishing for food:

increasing global competition for small pelagic forage fish.” Ambio. Vol. 38,

Iss. 6. September 2009 at 294.

14 Marine Aquaculture Task Force (2007) at 93.

15 Goldburg and Naylor (2005) at 24.

16 See Food & Water Watch. “Factory-Fed Fish: How the Soy Industry Is

Expanding Into the Sea.” June 2012.

17 Budiati, Titik et al. “Prevalence, antibiotic resistance and plasmid profiling

of Salmonella in catfish (Clarias gariepinus) and tilapia (Tilapia mossambica)

obtained from wet markets and ponds in Malaysia.” Aquaculture. Vol. 372-

375. January 2013 at 127.

18 U.S. Department of Commerce National Marine Fisheries Service. “Fisher-

ies of the United States 2012.” September 2013 at 81; U.S. GovOversight

Resources.” (GAO-12-933.) September 2012 at 5.

19 Government Accountability Office (GAO). “Seafood Safety: FDA Needs

to Improve Oversight of Imported Seafood and Better Leverage Limited

Resources.” (GAO-111-286.) April 2011 at 1, 5 and 7.

20 Food & Water Watch analysis of 2008 to 2012 FDA inspection data received

from a Freedom of Information Act (FOIA) request.

21 CDC. [Press release]. “CDC research shows outbreaks linked to imported

foods increasing.” March 14, 2012.

22 Love, David C. et al. “Veterinary drug residues in seafood inspected by the

European Union, United States, Canada, and Japan from 2000 to 2009.”

Environmental Science and Technology. Vol. 45, No. 17. September 1, 2011 at

7234.

23 Marshall, Bonnie and Stuart Levy. “Food animals and antimicrobials: im-

pacts on human health.” Clinical Microbiology Reviews. Vol. 24, Iss. 4. 2011

at 723.

24 Silbergeld, Graham et al. “Industrial food animal production, antimicrobial

resistance, and human health.” Annual Review of Public Health. Vol. 29. 2008

at 156; Smith, David L. et al. “Agricultural antibiotics and human health:

Does antibiotic use in agriculture have a greater impact than hospital use?”

PLoS Medicine. Vol. 2, Iss. 8. 2005 at 731.

25 Marshall, Bonnie et al. “Commensals: underappreciated reservoirs of resis-

tance.” Microbe. May 2009; Marshall and Levy (2011) at 728.

26 Silbergeld et al. (2008) at 152.

27 Alderman, D.J. and T.S. Hastings. “Antibiotic use in aquaculture: develop-

ment of antibiotic resistance – potential for consumer health risks.” Inter-

national Journal of Food Science and Technology. Vol. 33, Iss. 2. April 1998 at

139 to 155; Cabello (2006) at 1137 to 1138 and 1140.

28 Cabello (2006) at 1137.

29 Ibid.

30 Ibid.; Cabello et al. (2013) at 1920.

31 Heuer, Ole et al. “Human health consequences of use of antimicrobial

agents in aquaculture.” Clinical Infectious Diseases. Vol. 49, No. 8. 2009 at

1248 to 1249; Cabello (2006) at 1137 to 1138.

32 Sapkota, Amir et al. “Aquaculture practices and potential human health

risks: current knowledge and future priorities.” Environment International.

Vol. 34. 2008 at 1219.

33 Chelossi, Elisabetta. “Antibiotic resistance of benthic bacteria in fish-farm

and control sediments of the Western Mediterranean.” Aquaculture. Vol.

219. April 2003 at 83 to 97.

34 Esposito, Anthony. “Addicted to antibiotics, Chile’s salmon flops at grocers.”

Reuters. July 23, 2015; Cabello, F.C. “Antibiotics and aquaculture in Chile:

implications for human and animal health.” Revista Médica de Chile. Vol.

132, Iss. 8. 2004 at 1001.

35 Alderman and Hastings (1998) at 139.

36 World Health Organization. “Vaccinating salmon: How Norway avoids

antibiotics in fish farming.” October 2015.

37 Barrionuevo, Alexei. “Chile takes steps to rehabilitate its lucrative salmon

industry.” New York Times. February 4, 2009.

38 Cabello (2004) at 1001.

39 Esposito (2015).

40 Cabello et al. (2013) at 1918 to 1919.

41 Barrionuevo, Alexei. “Chile’s antibiotics use on salmon farms dwarfs that of

a top rival’s.” New York Times. July 26, 2009.

42 Cabello et al. (2013) at 1918 to 1919.

43 Cabello (2004) at 1001.

44 Cabello et al. (2013) at 1929.

45 Cabello (2004) at 1001.

46 Tomova, Alexandra et al. “Antimicrobial resistance genes in marine bacteria

and human uropathogenic Escherichia coli from a region of intensive aqua-

culture.” Environmental Microbiology Reports. Vol. 7, Iss. 5. 2015 at 803.

47 Cabello et al. (2013) at 1929.

48 Rico, Andreu. “Probabilistic risk assessment of veterinary medicines applied

to four major aquaculture species produced in Asia.” Science of the Total

Environment. Vol. 468-469. 2014 at 630 to 631.

49 Rico, Andreu et al. “Use of veterinary medicines, feed additives and probiot-

ics in four major internationally traded aquaculture species farmed in Asia.”

Aquaculture. Vol. 412-413. 2013 at 240.

50 Tracy, Tennille. “U.S. catfish fight expected to sink a popular import.” Wall

Street Journal. March 23, 2015.

51 Rico (2014) at 630.

52 Rico et al. (2013) at 231.

6

Copyright © April 2016 by Food & Water Watch. All rights reserved. This issue brief can be viewed or downloaded at foodandwaterwatch.org.

Food & Water Watch is safe, accessible and sustainable. So we can all enjoy and trust in what we eat and drink, we help people take charge of where their food comes from, keep clean,

quality of oceans, force government to do its job protecting citizens, and educate about the importance of keeping shared resources under public control.

53 Ibid. at 235 and 242.

54 Ibid. at 241.

55 See Thinh, N.H. et al. “Combined immersion and oral vaccination of Viet-

namese catfish (Pangasianodon hypophthalmus) confers protection against

mortality caused by Edwardsiella ictaluri.” Fish & Shellfish Immunology. Vol.

27. 2009 at 773 to 776.

56 Nguyen, Hoang Nam Kha et al. “Molecular characterization of antibiotic

resistance in Pseudomonas and Aeromonas isolates from catfish of the Me-

kong Delta, Vietnam.” Veterinary Microbiology. Vol. 171. 2014 at 397; Sarter,

Samira et al. “Antibiotic resistance in Gram-negative bacteria isolated from

farmed catfish. Food Control. Vol. 18, Iss. 11. November 2007 at 1391.

57 Nguyen et al. at 399 to 400.

58 Ibid. at 402.

59 U.S. Food and Drug Administration (FDA). “Detention without physical

examination of aquaculture seafood products due to unapproved drugs.”

Import Alert 16-124. November 16, 2015.

60 FDA. “Enhanced Aquaculture and Seafood Inspection – Report to Con-

gress.” November 20, 2008.

61 Tendencia, Eleonor and Leobert de la Peña. “Antibiotic resistance of bacte-

ria from shrimp ponds.” Aquaculture. Vol. 195, Iss. 3-4. April 16, 2001 at 193.

62 Doyle, Michael et al. “Antimicrobial resistance: challenges and perspec-

tives.” Comprehensive Reviews in Food Science and Food Safety. Vol. 12. 2013

at 244.

63 Le, Tuan Xuan et al. “Antibiotic resistance in bacteria from shrimp farming

in mangrove areas. Science of the Total Environment. Vol. 349, Iss. 1-3. Octo-

ber 15, 2005 at 95.

64 Boinapally, Kavitha and Xiuping Jiang. “Comparing antibiotic resistance

in commensal and pathogenic bacteria isolated from wild-caught South

Carolina shrimps vs. farm-raised imported shrimps.” Canadian Journal of

Microbiology. Vol. 53. 2007 at 922 to 923.

65 “Shrimp Report.” Consumer Reports. April 2015 at 35 to 36.

66 Ibid. at 45.

67 See Food & Water Watch. “The TPP Attack on Commonsense Food Safety

Standards.” December 2015.

68 Food & Water Watch analysis of FDA FOIA data and Import Refusal Report

2010 to 2014. Available at http://www.accessdata.fda.gov/scripts/ImportRe-

fusals/index.cfm. Accessed December 2015.